Primary sources are the legally binding source that you can cite to support your position as it relates to your fact pattern.
There are basically FIVE resources that you should be citing for your fact patterns.
1. Internal Revenue Code ( IRC )
2. Treasury Regulations, are all in Title 26 of the Code is assumed ( Treas. Reg. §Part Number.Section Number - SubSection Number )
3. Court Cases ( Number, Court Abbreviation, Number )
4. Tax Court Memorandum ( TCM )
5. Revenue Rulings as issued by the IRS ( Rev. Rul. Year - Number )
6. Other IRS publications, but typically these are the Internal Revenue Manual or an Internal Revenue Bulletin.
If there isn't ANY primary source information, you can argue your case using salient secondary resources such as academic research or related precedent from similiar situations (usually manifest in a court case).
What you should not do is cite any secondary explanatory resource that is intended to help you find the appropriate primary information or offer guidance about what the primary resource means as if it was a legally binding authority.
Tax is nine parts law, one part accounting.
Finding the best "point of entry" into the body of tax law will help you find relevant information in an efficient and effective manner. The US Master Tax Guide and the much more thorough US Standard Federal Income Tax Reporter are both well established tools to help you find the best point of entry efficiently and effectively.
Until you are aware of the specific verbiage and nomenclature of the tax law (or even your partciular tax sub-speciality), make use of the TOPICAL INDEXES.
Put what you *think* is the right term into the search mechanism of the electronic versions of the US Master Tax Guide and/or the US Standard Federal Tax Reporter and you will waste a lot of time and probably still not find the right information for your fact pattern. Use the TOPICAL INDEX to learn the vocabulary and find what you really need while saving yourself (and your client) a lot of time and frustration.
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